CRR Case Summaries and Entity-specific Press Notices

The FRC publishes, on a quarterly basis, summaries of its findings from recently closed reviews that resulted in a substantive question to a company (‘Case Summaries’). In addition, it publishes the names of companies whose reviews were closed in the previous quarter without the need for a substantive question. No Case Summary is prepared for such reviews.

Case Summaries, which are available for cases closed in the quarter ending March 2021 onwards, are included in the table below. As, currently, the FRC is subject to existing legal restrictions on disclosing confidential information received from a company, the Case Summaries can only be disclosed with the company's consent. Where consent has been withheld by the company, that fact is disclosed in the table.

From March 2018 until March 2021, the FRC published the names of companies whose reviews were closed in the previous quarter but did not prepare Case Summaries. However, on an exceptional basis, specific cases may be publicised through entity-specific Press Notices, which can also be found in the table below.

The FRC’s reviews are based solely on the company’s annual report and accounts (or interim reports) and do not benefit from detailed knowledge of the company’s business or an understanding of the underlying transactions entered into. They are, however, conducted by staff of the FRC who have an understanding of the relevant legal and accounting framework. The FRC’s correspondence with the company provides no assurance that the annual report and accounts (or interim reports) are correct in all material respects; the FRC’s role is not to verify the information provided but to consider compliance with reporting requirements. The FRC’s correspondence is written on the basis that the FRC (which includes the FRC’s officers, employees and agents) accepts no liability for reliance on its letters or Case Summaries by the company or any third party, including but not limited to investors and shareholders.

Key

  1. Only a certain number of CRR’s reviews result in substantive questioning of the Board. Matters raised may cover questions of recognition, measurement and/or disclosure.
  2. CRR’s routine reviews of companies’ annual reports and accounts generally cover all parts over which the FRC has statutory powers (that is, strategic reports, directors’ reports and financial statements). Similarly, CRR’s routine reviews of companies’ interim reports will generally cover all information in that document. Limited scope reviews arise for a number of reasons, including those conducted when a company’s annual report and accounts or interim report are selected for thematic review or reviews that have been prompted by a complaint. In accordance with the FRC's Operating Procedures, for Corporate Reporting Review, CRR does not identify those companies whose reviews were prompted by a complaint.
  3. The FRC may ask a company to refer to its exchanges with CRR when the company makes a change to a significant aspect of its annual report and accounts or interim report in response to a review.
  4. Case closed after 1 January 2021 but performed under operating procedures that did not allow for the publication of Case Summaries.
  5. From the quarter ended June 2023, the FRC started identifying the auditor of the annual report and accounts, or the audit firm that issued a review report on the interim report, that was the subject of the CRR review. This information was also back-dated for closed cases publicised from the quarter ended September 2022. Cases marked N/A relate to those published prior to September 2022 or interim reviews that did not have a review opinion.’

Case Summaries

CRR Case Summaries and Entity-specific Press Notices (Excel version)

1516 case summaries
Entity Team Internet Group Plc
Balance Sheet Date 31 December 2023
Exchange of Substantive Letters (1) No
Scope of Review (2) Limited
Quarter Published March 2025
Auditor (5) Crowe U.K. LLP
Case Summary / Press Notice N/A
Entity Tern PLC
Balance Sheet Date 31 December 2023
Exchange of Substantive Letters (1) Yes
Scope of Review (2) Limited
Quarter Published March 2025
Auditor (5) CLA Evelyn Partners Limited
Case Summary / Press Notice

Going concern

We requested clarification of the basis on which the directors satisfied themselves that the company was a going concern, and whether there were material uncertainties or significant judgements that should have been disclosed in making this determination. The company explained its assessment, why it believed that there was no material uncertainty, and that no significant judgement was involved. Nevertheless, we noted that some judgement was involved in this assessment given that the going concern status appeared to be dependent on events not wholly within the company’s control. In the light of this, the company agreed to consider carefully, whether the disclosure of a material uncertainty or a significant judgement may be necessary, should similar circumstances arise in the future.

Sources of estimation uncertainty

We enquired about the company’s disclosures under IAS 1, ‘Presentation of Financial Statements’ regarding major sources of estimation uncertainty in respect of the valuation of investments classified as Level 3 in the fair value hierarchy. The company explained that, as materially all of the valuations were based on the unadjusted price of a recent fundraise, the key estimates disclosed with respect to the valuation of investments were not sources of estimation uncertainty requiring disclosure under IAS 1. We closed our enquiry but encouraged the company to explain in future reporting that such disclosures represent uncertainties not within the scope of IAS 1. We also recommended that the company clarify the classification within the fair value hierarchy of these financial investments, and the methodology used in their valuation, as they appeared to represent Level 2 measurements

Entity The Edinburgh Investment Trust plc
Balance Sheet Date 31 March 2024
Exchange of Substantive Letters (1) No
Scope of Review (2) Full
Quarter Published March 2025
Auditor (5) PricewaterhouseCoopers LLP
Case Summary / Press Notice N/A
Entity The Pebble Group plc
Balance Sheet Date 31 December 2023
Exchange of Substantive Letters (1) No
Scope of Review (2) Limited
Quarter Published March 2025
Auditor (5) PricewaterhouseCoopers LLP
Case Summary / Press Notice N/A
Entity The Unite Group PLC
Balance Sheet Date 31 December 2023
Exchange of Substantive Letters (1) No
Scope of Review (2) Full
Quarter Published March 2025
Auditor (5) Deloitte LLP
Case Summary / Press Notice N/A
Entity Tullow Oil plc
Balance Sheet Date 31 December 2023
Exchange of Substantive Letters (1) Yes
Scope of Review (2) Full
Quarter Published March 2025
Auditor (5) Ernst & Young LLP
Case Summary / Press Notice

Kenyan Exploration & Evaluation (E&E) assets

We asked the company to explain the basis on which it used a value in use methodology to estimate the recoverable amount of the Kenyan E&E assets, as cash flows used in this approach should be limited to those arising from the assets in their current condition. The company provided further information about the progress of the project in question, which supported its value in use approach.

We asked the company to provide more information about the judgements made, assumptions and risk adjustments applied to estimate the portion of oil and gas resources that might be reserves in the future, so as to forecast the cash flows for the Kenya project, and whether this was considered to involve significant estimation uncertainty. The company satisfactorily provided the information requested, explained why it did not consider it to be a source of significant estimation uncertainty, and agreed to include this explanation in future sets of accounts.

In relation to the approach taken to assess the recoverability of the E&E assets, which involved risk-adjusting cash flows with a probability percentage reflecting estimated project success, we asked the company to explain what judgements it made when estimating this probability. We also asked the company to explain why neither information about the assumptions underlying the calculation of the overall probability percentage, nor the sensitivity of the calculation to changes in those assumptions, was disclosed in the accounts. The company explained the judgements performed, and the reasons why it believed that existing disclosures complied with the necessary financial reporting requirements but agreed to enhance disclosures to clarify the fact that the overall probability weighting drives the recoverable value of the E&E assets. We closed the point after acknowledging that IAS 1 requires the exercise of judgement by management in determining the extent of disclosures relating to significant estimates.

Climate-related metrics and targets disclosures

We asked the company to confirm the basis of calculation of its greenhouse gas emissions targets, as it appeared to be different to the basis on which emissions were reported in the accounts. The company explained the bases on which it calculated its targets and agreed to disclose data on all relevant bases going forward.

Impairment reversal

We asked the company to explain the basis for a large reversal during the year of a previously recognised impairment loss against the investment in a subsidiary. The company satisfactorily explained the events and circumstances which led to the reversal, and agreed to disclose this information, where relevant, in future sets of accounts.

Entity Volex Plc
Balance Sheet Date 31 March 2024
Exchange of Substantive Letters (1) No
Scope of Review (2) Full
Quarter Published March 2025
Auditor (5) PricewaterhouseCoopers LLP
Case Summary / Press Notice N/A
Entity Whitbread PLC
Balance Sheet Date 28 August 2024
Exchange of Substantive Letters (1) No
Scope of Review (2) Full
Quarter Published March 2025
Auditor (5) Deloitte LLP
Case Summary / Press Notice N/A
Entity Aberforth Smaller Companies Trust plc
Balance Sheet Date 31 December 2023
Exchange of Substantive Letters (1) No
Scope of Review (2) Full
Quarter Published December 2024
Auditor (5) Johnston Carmichael LLP
Case Summary / Press Notice N/A
Entity Admiral Group Plc
Balance Sheet Date 31 December 2023
Exchange of Substantive Letters (1) No
Scope of Review (2) Full
Quarter Published December 2024
Auditor (5) Deloitte LLP
Case Summary / Press Notice N/A
Entity Albion KAY VCT PLC
Balance Sheet Date 31 December 2023
Exchange of Substantive Letters (1) No
Scope of Review (2) Full
Quarter Published December 2024
Auditor (5) Johnston Carmichael LLP
Case Summary / Press Notice N/A
Entity Alpha Growth Plc
Balance Sheet Date 31 December 2023
Exchange of Substantive Letters (1) Yes
Scope of Review (2) Limited
Quarter Published December 2024
Auditor (5) PKF Littlejohn LLP
Case Summary / Press Notice

We asked the company for further information about the impact of IFRS 17 on the 2023 annual report and financial statements, as the audit opinion stated that ‘…[the auditor was] unable to obtain sufficient and appropriate supporting evidence to assess the impact of implementing IFRS 17 on the group’s financial statements’.

The company provided further information showing that the group had issued insurance contracts that were within the scope of IFRS 17, however, it explained that the Board believed that while the financial statements did not fully comply with IFRS 17, the impact on net assets would not have been material and would be presentational only.

The company agreed to fully implement the measurement, presentation and disclosure requirements of IFRS 17 in the 2024 annual report and accounts. In view of this undertaking and in the specific circumstances of the company, we did not consider it proportionate to take further action in respect of the 2023 annual report and financial statements.

Entity Alpha Growth Plc (3)
Balance Sheet Date 31 December 2022
Exchange of Substantive Letters (1) Yes
Scope of Review (2) Full
Quarter Published December 2024
Auditor (5) PKF Littlejohn LLP
Case Summary / Press Notice

Consolidation of insurance subsidiaries

We asked the company for further information about how the assets and liabilities of insurance subsidiaries had been presented in the consolidated financial statements, and the basis for presenting all assets and liabilities of insurance subsidiaries within a single asset and single liability line item in the consolidated statement of financial position, as this appeared to aggregate items which were not similar in nature. We also questioned why the cash and cash equivalents balances held by insurance subsidiaries were not reflected in the consolidated statement of cash flows.

The company explained that the financial assets held by the insurance subsidiaries are held solely to back the associated liabilities and that the presentation was adopted to clearly identify this. However, after further consideration the company agreed to restate the consolidated statement of financial position by providing appropriate disaggregation of the assets and liabilities of the insurance subsidiaries. The company also agreed to restate the consolidated statement of cash flows to include cash and cash equivalents held by insurance subsidiaries.

Revenue of Alpha International Life Assurance Company (AILAC)

We asked the company for further information about the terms of the acquisition of Alpha International Life Assurance Company (AILAC), and in particular the point at which income in relation to AILAC was recognised. The company explained that control of AILAC was achieved upon receiving regulatory approval in November 2022, but also noted that a fee was charged for management and advisory services performed from August 2022.

Segmental reporting

We asked the company for an explanation of the basis on which they concluded that the company has a single operating segment. The company provided a satisfactory explanation; however, we noted that this matter should be kept under review as the company grows.

Future impact of IFRS 17, ‘Insurance Contracts’

We questioned the company’s assertion that IFRS 17 would not have a material impact on the group, given the nature of the company’s business, and asked for further information about the nature of the contracts issued by the insurance subsidiaries. The company explained that the majority of the contracts issued by the insurance subsidiaries do not contain significant insurance risk but that it was assessing the impact of IFRS 17 on those contracts that do contain significant insurance risk.

Recoverability of Interval Fund Expenses

We asked the company for further information about the recoverability of the interval fund expenses recognised as a receivable by the company. The company provided a satisfactory explanation.

TCFD disclosures

We noted the limited TCFD reporting and asked the company to explain what additional or improved disclosures it expected to make in its next annual report and accounts. The company agreed to consider our thematic reviews and expand the TCFD disclosures in the next annual report and accounts.

Earnings per share

We questioned the calculation of diluted earnings per share, as options and warrants were shown to be dilutive, despite having a weighted average exercise price which appeared to be above the average market price of ordinary shares in the period. The company agreed to restate the calculation of diluted earnings per share in the next annual report and accounts.

Other disclosures

We asked the company to enhance its disclosures in relation to (i) key performance indicators (KPIs) in the strategic report, (ii) the management of capital, (iii) fair value of financial instruments, and (iv) liquidity risk. The company agreed to make a number of disclosure enhancements in its next annual report and accounts in these areas.

Entity CAB Payments Holdings plc
Balance Sheet Date 31 December 2023
Exchange of Substantive Letters (1) No
Scope of Review (2) Full
Quarter Published December 2024
Auditor (5) Forvis Mazars LLP
Case Summary / Press Notice N/A
Entity Card Factory plc
Balance Sheet Date 31 January 2024
Exchange of Substantive Letters (1) No
Scope of Review (2) Limited
Quarter Published December 2024
Auditor (5) Forvis Mazars LLP
Case Summary / Press Notice N/A